How to Become a Tobacco Wholesaler in the UK

Everything seems to be going well. You have found legitimate suppliers, secured a warehouse or storage facility and started speaking to retailers or marketplaces interested in buying tobacco products from you.

Then your supplier or a clearance house asks you to provide the following:

   “What are  your  Economic  Operator  ID and Facility  ID?”  

This is where many new tobacco wholesalers find out that just registering a company was not enough.

Businesses that manufacture, import, transport, store or sell tobacco products in the UK are required to follow the Tobacco Track and Trace regulations. The core requirements of the regulations are intended to ensure that products are legitimate, and that necessary information is recorded and made available about their movements through the supply chain from manufacture or import to the first retail outlet.

For a wholesaler, this means you must register with the UK ID issuer, obtain your identification codes, and begin capturing and reporting tobacco movements before you begin trading.

Do Tobacco Wholesalers Need a Licence?

There is no specific overall tobacco wholesale licence. However, tobacco businesses have been required to register for the UK Tobacco Track and Trace system.

Originally, this applied only to cigarettes and hand-rolled tobacco. As of 20 May 2024, it also covers all other tobacco products, such as cigars, cigarillos, pipe tobacco and snuff.

Vaping goods are not included in the system purely because they are nicotine-containing products. Vapes have their own separate product, duty and regulatory requirements.

You should register whether you sell to retailers, store in a wholesale warehouse, transport between facilities, or import tobacco into the UK.

Economic Operator IDs and Facility IDs

It all starts with an Economic Operator ID, commonly referred to as an EOID.

This ID is used to identify the company or operator who is part of the tobacco supply chain.

After that, you’ll need a Facility ID or FID for each storage, distribution, or sales premises of tobacco products.

Identifier	What it represents
Economic Operator ID	The business or economic operator
Facility ID	An individual warehouse, shop or other tobacco premises
Machine ID	Manufacturing machinery, where applicable
Unique Identifier	The code placed on tobacco packaging to track the product

For example, a wholesaler is likely to need one EOID for the business and a separate FID for each warehouse or relevant trading premises.

If one premises sells tobacco to retailers and the public, two Facility IDs will be needed: one for wholesale and one for retail.

Getting these doesn’t cost anything, but as current government guidelines say an EOID may take up to two working days to be issued, it’s best not to wait until you need your first consignment of tobacco.

How to Register

The UK ID issuer is currently Dentsu Tracking.

To obtain an ID, register through the UK ID Issuer service for Tobacco Track and Trace. You will be asked for information, including:

• Your business name and address
• VAT registration number or Corporation Tax Unique Taxpayer Reference
• A Global Location Number, if you use one
• Your billing details if you will request product identifiers
• Details of the facilities connected to the business

When you’ve been issued with your EOID, you must register each of your premises, including warehouses, with the ID issuer to get its FID. 

You must keep your EOID and FIDs up to date. Any changes to your business or premises details must be updated using the issuer’s service. 

You must have an EOID to obtain a FID. Both EOIDs and FIDs are required whenever tobacco products are bought, sold or moved through the regulated supply chain.

Scanning Tobacco Products

Tobacco packaging sold in the United Kingdom is assigned a Unique Identifier (UID). It is used to trace both individual and groups of packs throughout the distribution channel.

Wholesalers need appropriate scanning equipment and software. Products must normally be scanned when they:

• Arrive at a wholesale facility
• Leave the facility
• Move between premises with different Facility IDs
• Transfer between vehicles without entering a facility

Products must be scanned when transferred from one vehicle to another without passing through a location. The associated movement information must then be transferred to the UK Gateway. 

This implies that a wholesaler should be aware of the Facility ID of the goods’ source, the current location of the stored goods, and the ID of the intended destination facility. 

It is not sufficient to add products to a standard inventory database. The designated UID movement and event information must be correctly reported to the appropriate Track and Trace systems.

Recording Orders, Invoices and Payments

The Track and Trace system covers more than physical warehouse movements.

You need to let us know about certain events relating to sales of tobacco, for example when you:

• Issue an order number
• Generate an invoice
• Receive payment

The data you provide about the event may include the seller and buyer IDs, invoice details, purchase order reference, payment process, tobacco value and quantity, and tobacco product identifiers.

We require you to send information within 24 hours of learning that the event has occurred, including the UIDs that correspond to the event. Your commercial records and warehouse records must match up. For example, if an invoice is issued for one customer but the stock movement is recorded against a different premises, the discrepancy will need to be investigated.

This can apply to:

• Retailers
• Suppliers that sell to other businesses
• Businesses storing products on behalf of someone else

Tobacco suppliers in Northern Ireland may also be within the scope of the EU Track and Trace System and the UK system.

Supplier and Customer Checks

A tobacco wholesaler must only trade with entities that have the necessary IDs to fulfil their function in the supply chain.

Before making a supply to a retailer, obtain the customer’s EOID and the FID of the premises to which the goods are to be supplied. The same applies to purchases from another operator.

You are also required to keep accurate records of:

• Approved suppliers and customers
• EOID and FID details
• Purchase and sales orders
• Delivery and movement records
• Invoices and payments
• Returns and damaged stock
• Any identifier or reporting errors

Keeping proper records linked together facilitates cross-checks of physical stock, commercial documents and submitted Track and Trace events.

Track and Trace Is Not the Same as Tobacco Duty

Track and Trace registration does not remove your tax and excise responsibilities.

Businesses producing, holding, moving, or importing tobacco products must register with Track and Trace and ensure they comply with all applicable tax and duty regulations.

Tobacco Products Duty becomes due on tobacco products as soon as they are imported, manufactured, or first received in the UK in a condition ready for consumption.

Importers may also need to account for customs declarations, Customs Duty, import VAT, fiscal marks, and any commodity-specific requirements.

Businesses importing tobacco that they wish to store without paying duty in advance will need to apply to register a tax warehouse, an excise warehouse, or a registered store, depending on whether the tobacco will be stored in duty suspension after production or import, during processing or further processing after production or import, or after the tobacco products have been released for consumption. 

Holding other people’s processed tobacco in an excise warehouse or store will require Special Procedures approval.  

Manufacturers and importers may also need to get their products registered and, where necessary, apply for a manufacturing Unique Identifier (UID).

Penalties for Non-Compliance

HMRC and Trading Standards have the right to visit premises and investigate tobacco products they believe may be illicit or non-compliant.

Not following Track and Trace can lead to:

• Financial penalties of up to £10,000
• Seizure and possible destruction of tobacco products
• Temporary or permanent deactivation of an EOID
• Loss of the ability to buy or sell tobacco legally in the UK

The level of penalty and how it is applied may depend on how much non-compliant product is involved and whether you have had previous offences.

An EOID may be deactivated if you do not meet obligations, if there are significant customs or excise penalties, for relevant convictions, or if there is prolonged inactivity.

Final Thoughts

Becoming a tobacco wholesaler in the UK involves more than registering a company and purchasing stock.

Your business must be identifiable within the Tobacco Track and Trace system, each relevant facility must be registered, and product movements must be scanned and reported correctly.

The strongest approach is to build compliance into your warehouse and order processes from the beginning. Clear supplier records, accurate facility information, and consistent stock movements make it easier to operate legally and respond when a transaction or product requires investigation.

References

• HM Revenue & Customs, Register with the UK ID Issuer if Your Business Is Involved in the Supply of Tobacco Products
• HM Revenue & Customs, Selling and Storing Tobacco Products
• UK Tobacco Track and Trace ID Issuer Portal, Dentsu Tracking
• GOV.UK, Tobacco Product Traceability Guidance Collection
• HM Revenue & Customs, Registration Process for UK Tobacco Track and Trace
• HM Revenue & Customs, Operation of the UK Tobacco Track and Trace System
• HM Revenue & Customs, Overview of the UK Tobacco Track and Trace System
• HM Revenue & Customs, Tobacco Track and Trace Penalties
• HM Revenue & Customs, UK Tobacco Track and Trace Penalties and Sanctions Factsheet
• HM Revenue & Customs, Import Tobacco Products into the UK
• HM Revenue & Customs, Tobacco Products Duty
• HM Revenue & Customs, Excise Notice 476: Tobacco Products Duty
• HM Revenue & Customs, Receiving, Storing and Moving Excise Goods
• UK Legislation, The Tobacco Products (Traceability and Security Features) Regulations 2019